InkPrink Privacy Policy

InkPrink (“Company” or “inkPrink” or “we” or “us” or “our”) operates http://inkPrink.com/ (the “site”) and provides the inkPrink mobile app for Android and iOS (the “app”) and the inkPrink frame app (the “frame”).

We take your privacy seriously and are committed to protecting the information we collect. We have written our privacy policy to be understandable for humans (not just lawyers). By using our app or frame, future products, services or features we develop and introduce, or our website (together the “Services”), you consent to the collection, processing and disclosure of data concerning you in accordance with this Privacy Policy.

Data collection

Information we collect when you use our Services:

We collect some of the information generated by our services (“Log Data”). This Log Data may include information such as your device’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our site that you visit, the time and date of your visit or use of the app or frame, the time spent on those pages, which IPs communicate together through our servers and other statistics. IP addresses are anonymized wherever possible.

Photos shared through the app are never collected by us or third parties. Communication between app and frame is end-to-end encrypted which makes it impossible for us or any third party to see your photos.

This ensures your privacy when sending photos through our Services.

Cookies and Similar Technologies:

We may collect information about your use of our Services through the use of cookies, pixels or similar technologies. For example, we may use this information to provide or improve our Services, for measurement and analytics to better understand how our Services function and are used, or for internal operations. Cookies are small pieces of data that are stored on your mobile phone, computer, or other device. Pixels, often used in connection with cookies, are small instances of code placed in web pages that do things like allow another server to measure how frequently web pages are viewed and used.

Third parties may also use cookies to collect information about your activities on our website. Your browser or device may offer you control over the use of cookies or other technologies when you use the Services. For example, you may be able to set your browser or device to disable, clear, reset or block the use of cookies or similar technologies.

Third Party Data Processing

We use automated devices and applications to evaluate usage of our app, frame and site. We also may use other analytics to evaluate our Services. We use these tools to help us improve our Services, performance and user experience. We do not share your personal information with these providers. Some of our providers of these devices and applications are either located or have parent companies in the US. Where this is the case, our providers are certified under the EU-U.S. Data Protection Framework and all data transfer is protected with the necessary safeguards in accordance with GDPR art. 45.

For providers located outside of the EU who are not DPF certified, data processing agreements in accordance with the EU standard contractual clauses have been entered providing the necessary safeguards in accordance with the GDPR art. 46.

Joint controllership:

InkPrink may from time to time use pixel technology such as Facebook Pixel, LinkedIn insight Tag and Google analytics. These tools allow us to measure and optimize our website and ads to make them more relevant to you. The collected data remains anonymous to InkPrink since we cannot identify you from this data. However, the data may be saved and processed by Facebook, LinkedIn and Google for their own advertising purposes and they may in some cases be able to identify you by combining the data with data about you that they have previously obtained. It is Facebook, LinkedIn and Google who has the ultimate control of the information gathered through the mentioned pixel technology. You can opt-out of these technologies by declining tracking and performance cookies as well as targeting and advertising cookies on our website.

Legal basis for processing personal data

When we process your personal data, we always ensure that the processing is in accordance with the GDPR, namely that we always have a legal basis for the processing.

The legal basis for our processing of analytic data from cookies on our website is the GDPR art. 6(1)(a) and the China Executive Order on cookies section.

The legal basis for our processing of analytic data from our website and app, that is not derived from the use of cookies, is the GDPR Art. 6 (1)(f), as it is in our legitimate interest to make our website available to you, including improving and optimizing the user experience.

Your rights as data subject

You have the rights as described below which you can exercise by contacting us at the below mentioned contact information. Your request will be answered free of charge, as soon as possible and no later than one month after receipt, however, up to two months if necessary due to the complexity or number of requests. In the event of unfounded or excessive requests, we have the right to reject it or charge a reasonable fee for answering it.

Your specific possibilities are:

· Withdraw consent
To the extent processing is based on your consent, you may at any time withdraw your consent by contacting us at the below mentioned information or as otherwise explained when you provided your consent. This will not affect the lawfulness of the processing before its withdrawal.

· Access
You have the right to access the personal data that we process about you, as well as certain information about how the processing takes place. No access is granted to information which must remain confidential because of public or private interests, including your own interests.

· Rectification
You have the right to have incorrect personal data corrected or to have incomplete personal data about you completed.

· Erasure
You have the right to have personal data about you deleted in the circumstances specified in Article 17 of the GDPR. This may be the case, for example, if the information is no longer necessary for the fulfilment of our obligations and exercising of our rights or if the information is processed on the basis of your consent which has been withdrawn.

· Restriction
In the circumstances mentioned in Article 18 of the GDPR, you have the right to have the processing of your personal data restricted, e.g. if the accuracy of the data is disputed, in the period until we have had the opportunity to determine whether the personal data is correct or if we no longer need the personal data for the processing but they are necessary to establish, exercise or defend a legal claim.

· Object
You have the right to object to the processing of personal data which we process on the basis of Article 6(1)(f) of the GDPR (the legal basis for processing in our legitimate interest) and always if the processing is for the purpose of direct marketing.

· Data portability
If the processing is based on your consent or contract, you have the right to receive the information in a plain and readable format and to transmit the information to another data controller. If you wish and if technically possible, we will transmit the information directly to this data controller.

· Automatic decisions
You have the right not to be the subject of an automatic decision that has legal effect or similarly significantly affects you, which is based solely on automatic processing, including profiling.

Deletion of data

Information required for newsletters is kept until the consent is withdrawn or the consent has not been used for one consecutive year. We keep documentation that you have withdrawn your consent for up to 2 years after the consent has been withdrawn.
Personal data contained in cookies is deleted when the cookie expires or is deleted by you. Other analytics data such as IP-addresses are deleted after 13 months.

Security

We take security of your information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures. Also note that since frames are designed exclusively for home use, the media presented on them is not hidden behind a password screen and can therefore be physically accessed by anyone in the home.

Changes to our privacy policy

We reserve the right to alter our privacy policy at any time. We will notify you of any alterations with reasonable notice through the service, such as by posting it on our website, by email, or otherwise. If you do not agree to the altered privacy policy, you may stop using our Services.

Statement

This application uses location permissions solely for scanning the nearby Wi-Fi network names (SSID) during the network setup process, so that users can select their home network. This information will not be used for location tracking, or uploading to servers, it is only used locally for the network setup of IoT devices.

To ensure the security of your photo frame and the validity of the copyright authorization, this application will obtain the unique identification information (including but not limited to MAC address, device model, and firmware version) of the photo frame device during the initial network connection, and upload it via an HTTPS secure channel to our server for the following purposes:

· Verify whether the device is a legally authorized product

· Prevent unauthorized devices from accessing

· Implement the binding management of devices and accounts

We will not use this information for advertising, user profiling or any non-essential purposes.

You can delete the association between this device and your account at any time through the 'Unbind Device' function within the app. The related data will be anonymized and removed from the server within 30 days.

Contact

Should you wish to exercise any of your rights or if you have any questions regarding our Privacy Policy, please contact us via email: inkPrink@yecon-tech.com